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reLAKSation no 1072

Regulation: Fish Farmer Magazine reported from the Aquaculture UK show which was officially opened by the Rural Affairs Minister Mairi Gougeon. The Minister told the audience at Aviemore that she is the champion for the aquaculture sector in Scotland, something which is widely welcomed.

She also said that she aims to deliver the recommendations made by Professor Russell Griggs following his review of the regulatory process. This includes a variety of different measures of which one is specifically of interest. Professor Griggs had suggested the creation of a central science and evidence base which should be jointly managed by the industry and Scottish Government. This would gather, collate, and examine scientific evidence relating to the sector allowing any decisions to be made in the most effective way.

The Minister told Aquaculture UK that she intended to task the Scottish Science Advisory Council (SSAC) to consider the scientific recommendations of the review, however whilst there is urgent need to change the way science relating to aquaculture is evaluated, I am not sure that the SSAC is the right way to go. This is because there is no specific specialised expertise within the group that would help judge the validity and nuances of aquaculture science.  The problem at the moment is that Marine Scotland Science (MSS) appear, not only to be the only arbitrators of the science, but that their interpretation of the science is closed to challenge. What is needed instead is a group consisting of representatives of Scottish Government, industry, and academia, who need to be in agreement before any science is applied to policy. Currently, the science put forward, especially about sea lice, is the subject of significant dispute. This is not something new or recent but has been at the heart of questions about industry development for many years and is something that has never been addressed. Part of the problem is that most research is aimed at showing that sea lice do have an impact on wild fish rather than not. In addition, those who try to show that sea lice have an impact appear uninterested in any research that shows that they don’t. This is not helped by the lack of any appropriate forum to discuss the differences.

Yet such differences exist as can be seen by comments made by the Minister during her address at Aquaculture UK. She said that it is important to recognise the significant progress made since the Scottish Parliament Committee’s inquiries into salmon farming through the Salmon Interactions Working Group (SIWG) and the recent SEPA sea lice risk assessment framework consultation for wild salmon.

In terms of science, the Scottish Parliament Environment, Climate Change and Land Reform Committee commissioned a report from SAMS Research Service into the environmental impacts of salmon farming. Chapter two of the report included a review of the impacts of sea lice on wild fish. This was written by Professor Eric Verspoor, a well-known fish geneticist and not someone who is associated with problems about sea lice. The question as to why SAMS did not use a specialist sea lice scientist to write this chapter remains unanswered, but the content of the chapter did not provide a balanced view of the issues surrounding sea lice.

Discussion of the science about sea lice impacts also failed to materialise during the various meetings of the SIWG. In fact, because the issue was so contentious, the group avoided any discussion of the science. This was a major deficiency, especially for the industry as this was a real opportunity to resolve the scientific issues. Unfortunately, the then non-scientific industry lead agreed to proceed with SIWG without such discussion, and this is possibly one of the reasons why this person is no longer involved in the industry. The group was also unbalanced in its make-up in favour of those opposed to salmon farming, so any discussions about getting to the truth of the science would have been a major challenge anyway.

Finally, I come to SEPA’s sea lice risk framework consultation, which I have discussed previously. The scientific rationale for adopting this framework is exceptionally poor. It will do nothing to save wild salmon and sea trout and even though the science does not justify the imposition of this approach, it is likely that we will see it inflicted on the industry. This is because SEPA’s view is that they have been charged to progress this framework by the Minister and they will do so regardless of any evidence to the contrary.

The problem is that the need for this framework has developed out of the MSS Summary of Science which has been posted in various forms over several years on the Scottish Government website. According to Marine Scotland, this summary has not formed Government policy and when asked which science has been used to formulate policy, the reply has been SIWG, even though SIWG did not discuss the science. In my view, the science presented in the summary has been selected to present a specific narrative which is why MSS don’t seem to want to discuss its validity and relevance.

It also doesn’t help that in addition to drawing up this scientific summary, MSS also initiated development of the sea lice risk framework and they now don’t want to be shown to have got it wrong, and sadly I believe they have. This is why we urgently need some form of expert group that encompasses views other than those of MSS. At the moment, there is absolutely no forum for discussing the science other than if MSS is willing to do so, which it mostly is not.

It is exactly because there is no forum for discussion of the science that the mistrust, dislike and vitriol between regulators, parts of Scottish Government, industry and other interested parties identified by Professor Griggs, has been allowed to develop. With very little openness about the science, regulators have over time imposed increasingly stringent and unnecessary regulation on the salmon farming industry. It now seems that it is easier to get planning permission for a nuclear reactor than for a salmon farm and yet the salmon farm is not even a permanent structure, just a floating platform anchored to the seabed. I would argue that the anti-salmon farm narrative that exists is because of what I would describe as the selective use of science about sea lice.

The way that this Summary of Science impacts on the salmon farming industry can be shown by the latest newsletter of the Coastal Communities Network (CCN), whose aquaculture group met with Nature Scot and SEPA to discuss addressing the cumulative impacts of fish farming and the statutory advice provided to other agencies. As a result of this meeting, Nature Scot have agreed to review their internal guidance to reflect changes to MSS’s Summary of the Science on the impacts to wild fish from sea lice. CCN say that this summary shows that basically a risk exists).  I would vehemently disagree, yet there is no forum for me to express that view other than through this weekly mailing. It’s no wonder that Professor Griggs was so exasperated by the mistrust, dislike, and vitriol he uncovered. He is not the only one.


Postscript: Whilst on the subject of the Aviemore show, it was notable that not one of the industry critics, whether those inhabiting social media, groups like the CCN, NGOs like Feedback or Future Markets, or angling groups or fisheries representatives, such as Salmon and Trout Conservation or Fisheries Management Scotland attended the event to express their view, especially as the minister was in attendance. They all have one thing in common and that is a readiness to criticise the industry as long as they are in a position where they are never challenged. However, as soon as there is the possibility that they may come up against people who are willing to stand up and challenge their narrative, they all run a mile. Given the Government’s commitment to the industry, perhaps even Marine Scotland should have had visible representation at the show.


Risk report: By coincidence, the Institute of Marine Research in Norway has published its latest risk report. Unsurprisingly, the biggest risk to wild salmon and sea trout in Norway is perceived to come from sea lice and genetic introgression. This shouldn’t be unexpected because like in Scotland, the risk is perceived by a small group of scientists, who have vested interests, rather than a wider scientific body. The international group of scientists who were charged to look at the Traffic Light System expressed a similar view.

Clearly, this risk assessment is controversial, because when one of the authors Ellen Sofie Grefsrud described their new method of risk assessment back in March, she said to stress that the new method had been published in a scientific journal after peer review. She added that had their work not held up to scrutiny then the paper would not have been published. However, just because the new method had been published does not mean that it is either exact or right.

The problem with such risk assessment and other risk approaches, based on modelling, is that they don’t reflect what is actually happening in the sea. For the last few years, the scientific committee for salmon management have claimed that the estimated (and unproven) death of around 40,000 smolts due to sea lice is a much greater threat to the salmon population than the actual confirmed deaths of over 100,000 adult breeding fish that have been killed by anglers for sport. This makes no sense. Surely, the loss of breeding stock in such numbers undermines the future safeguarding of wild salmon in Norway. By comparison, the perceived loss of smolts to sea lice is just conjecture.

In both Scotland and Norway, the scientific communities have yet to accept that the aggregated distribution of sea lice on sea lice trout shows that the risk to wild fish has been highly overstated. I would suggest that the biggest risk to wild fish comes not from sea lice but from scientists who refuse to consider or discuss that there might be a different narrative to the one that they espouse.


Market development: According to Fish Farming Expert, salmon prices reached a record high towards the end of last month. Analysts are predicting that salmon prices will remain high with strong demand due to reduced supplies. I am not of the same view. This is because once these high prices to filter through the consumer market, demand will fall. Over many years, I have seen this happen time and time again. There is only so much that consumers are willing to pay for salmon. This happens even in strong fish consumption markets such as France. Some years ago, an extremely critical TV documentary was shown in France and subsequently demand collapsed. It took some months to recover. The Norwegians blamed the documentary, but the reality was that coincidentally salmon prices soared at the same time and demand fell away to the extent that salmon almost disappeared from fish counters. Instead, it was replaced by cod, sales of which were driven by heavy discounting. Once retail salmon prices realigned with other foods, then demand returned, and salmon regained its leading position in the market, but it took some time to happen.

In the UK, the current situation could be very different. If salmon prices rise too far, consumers will not turn to other fish but to other proteins instead. Salmon is perceived more as a protein rather than just another fish.

Yet, the current situation may be unique in price development history. In the past, demand has usually been linked to supply but now, rising costs may be a greater influence on prices for some time to come and less easy to remedy.

This week, two analytical companies have evaluated the market for fish and forecast reduced demand ahead. Salmon Business report that NielsenIQ are seeing a reduced sales not just of fish but also other proteins as the rise in the cost of living begins to bite. In the last four-week period, sales fell by 13% whilst values have fallen by 7.8% year on year. Sainsbury’s have said shoppers are now watching every penny.

The market research company Kantar have taken a deeper look at the fish sector. Seafood Source report that seafood sales dropped 8.3 percent in the quarter to the end of March. Kantar sees this as the result of inflation and higher prices. Yet, Kantar says that seafood sales are holding strong when compared to other proteins even though all categories have seen sales fall, including natural (down 11.2%) and smoked (down 12.6%). These represent the whole fish sector not just salmon. Added value fish was the only category to see an increase, rising 4.3% compared to last year, although it is not clear what products are actually included in this category.

Kantar says that one reason why protein sales are falling is because the public is returning to eating out so reliance on home cooking has declined. Yet, with the cost of living rising, whether eating out can be sustained must be questioned.

Over the past few weeks, some retailers have attempted to increase the price of salmon, but such increases have been followed by promotional discounting meaning that the price remains unchanged for at least some of the offering. Last week, the discounter Lidl increased prices across the board which should prompt Aldi to follow suit and then those supermarkets that price match with Aldi to follow too, but as yet, such changes have yet to materialise.

In my experience, retailers are relatively slow to change prices, preferring to wait and see how market prices develop first. Often retailers appear to absorb any price change in the short term so they can maintain market share.

What is clear is that if salmon prices do rise above current levels, demand will undoubtedly fall, and this will have an inevitable knock-on effect on supply and on prices, yet, with higher costs, farmers might well feel the squeeze.

I keep getting asked for my view on demand and prices, but as we are now entering totally new ground, there is bound to be some uncertainty, at least in the short-term. I will certainly be keeping watch.